Friday, April 30, 2021
The International Tax Policy Forum hosts a conference today on "Whither International Taxation: A New International Tax Architecture Based on the OECD Blueprints?" (program):
The architecture for international tax relations among developed economies was established almost 100 years ago by the League of Nations. Over the last few years, however, historic concepts regarding jurisdiction to tax, attribution of profits to permanent establishments, and arm’s-length pricing have come under pressure. Notable developments include: the UK diverted profits tax, digital services taxes and levies enacted or proposed in over 40 countries, and the US Base Erosion and Anti-abuse Tax (BEAT).
In October of last year, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting released two Blueprints proposing new guidelines for the taxation of multinational enterprises (MNEs). The Pillar One Blueprint reallocates the right to tax certain high-margin income of MNEs on the basis of sales or users. Pillar Two sets forth a model minimum tax on the income of foreign subsidiaries along with rules for denying deductions (or imposing withholding tax) on payments not subject to a minimum rate of tax in the payee jurisdiction. The Biden Administration has endorsed the OECD/G20 project and agreement on open issues is targeted for the middle of this year.
This conference brings together experts from academia, government, and private practice to share their views on challenges to the international tax architecture and the OECD Blueprints.
Overview of the OECD Blueprints:
- Mary Bennett (Baker McKenzie)
Are New Rules Needed for Taxing International Income?:
- Wei Cui (British Columbia)
- Mihir Desai (Harvard)
- Jim Hines (Michigan)
- Ruud de Mooij (IMF)
- Wolfgang Schön (Max Planck Institute, Munich)
Should a New International Tax Architecture Be Based on the OECD Blueprints?:
- Michael Devereux (Oxford)
- Michael Graetz (Columbia)
- Chip Harter (PwC)
- Will Morris (PwC) (moderator)
Keynote Address: Pascal Saint-Amans (Director, OECD Centre for Tax Policy & Administration)